Allergens in Hot Drinks Advice

Introduction

Pembrokeshire County Council has recently carried out food standards sampling, looking for the presence of dairy milk in non-dairy coffees. A selection of food premises in Pembrokeshire were visited and asked for a dairy-free coffee, suitable for someone with a milk allergy. 83% of the samples tested contained traces of milk and 67% contained sufficient milk protein to potentially cause serious harm or even death to someone with a milk allergy. These results, further to the tragic death of a milk allergy sufferer following consumption of what was believed to be a dairy, milk-free hot chocolate purchased from a retail outlet in the UK, has prompted this advice leaflet to Pembrokeshire businesses on the controls required when a customer requests an allergen free hot drink.

Food Information and Safety Laws: Allergenic Ingredients

Food Information Law: Allergenic Ingredients

If you are asked about allergenic ingredients in a drink, you are required by law to inform customers which of the 14 allergens it contains. This must include the ingredients of ingredients, such as any powders, toppings, sprinkles or syrups used within the drinks. Any precautionary allergen statements on ingredient lists should also be considered, ensuring that they are appropriately communicated as ‘may contain’ rather than actual ingredients.

The information that you provide to customers on allergens must be accurate, consistent and up-to-date.

The 14 allergens are:

celery
cereals containing gluten (such as wheat, rye, barley, and oats)
crustaceans (such as prawns, crabs and lobsters)
eggs
fish
lupin
milk
molluscs (such as mussels and oysters)
mustard
peanuts
sesame
soybeans
sulphur dioxide and sulphites (if the sulphur dioxide and sulphites are at a concentration of more than ten parts per million)
and tree nuts (such as almonds, hazelnuts, walnuts, brazil nuts, cashews, pecans, pistachios and macadamia nuts)

Food Safety Law: If You Are Asked If a Drink Contains Allergens

If you are asked about allergens, please be aware that it is very difficult to provide a meal or drink that is completely free of all allergens in a small and busy premises.

You might wish to tell the customer:

“These are the allergens which the drink contains… BUT I cannot guarantee that the drink will be completely free of the ingredient which you are allergic to because tiny amounts of allergens may be present in ingredients which I buy in, due to cross contamination.”

If you use the allergenic ingredient in your premises, you might want to say:

“These are the allergens which the drink contains… BUT I cannot guarantee that the drink will be completely free of the ingredient which you are allergic to because I do use this ingredient in my premises and tiny amounts of allergens may be present due to cross contamination from equipment during the day / evening.”

For example, if you are asked to provide a milk-free drink and use milk powder in other drinks on your premises, this milk powder could easily contaminate other surfaces and equipment, even if this contamination is not visible to the naked eye.

Please note that you are NOT required by law to provide a drink that is completely free of an allergen, as it may be extremely difficult to avoid contamination or cross contamination. You should explain this to the customer.

Talking to Customers About Allergies

When talking to customers with allergies, be careful that they understand you and that you understand them.

Sometimes customers may feel embarrassed talking about their allergy and may not explain it very carefully.
Sometimes customers may have been drinking alcohol, which might affect their judgement.
Sometimes customers may have ordered a drink before and not realize that you use a different recipe to the one they are used to or have changed an ingredient.
Sometimes customers may think their allergy is only mild, but allergies can get worse over time.

Preparing a Drink Without a Particular Allergen

Understanding and Agreement:

If the customer is provided with all the necessary information and both you and the customer definitely agree and understand, you may decide to serve a drink made without the allergen.

Cleaning Procedures

Equipment Cleaning:

Use fresh, very hot water, rubber gloves, detergent, sanitiser (that meets BS standards) and fresh cloths to clean all equipment.
Ensure all equipment that the drink would come into contact with is cleaned and sanitised, including pourers, jugs, spoons, milk thermometers, cups and lids.

Coffee Machine Sanitisation

Sanitise Thoroughly:

Ensure water and steam pipes, wands, and nozzles that may have been in contact with allergen-containing products are carefully sanitised using a two-stage clean to remove all traces of allergens. Consider whether deposits of any allergen, for example milk proteins could remain inside of the machine, particularly in the steaming nozzle.

Beware of Splashes:

Re-sanitise equipment prior to preparing an allergen-free drink to avoid contamination from nearby prepared drinks.

Steaming / Heating Nozzle

If you don’t have a separate nozzle to heat milk for each type of allergen-free drink, discuss alternative menu choices with the customer which may allow cold milk to be used in their drink, or heat the milk for their drink using an alternative heat source such as a microwave.

Check Cleaning Functions:

Automatic cleaning functions on coffee machines may not be effective in removing all traces of allergens. Discuss with machinery suppliers or manufacturers.

Surface and Hand Hygiene

Surface & Equipment Cleaning:

Clean work surfaces thoroughly using hot water and detergent, dry with paper towel, then clean again using a sanitiser or disinfectant (two stage clean). Check if the sanitiser needs to be left on the surface for a specific time (5 minutes is common).
The rougher the surface, the harder it is to remove an allergen, so textured nozzles etc. on the end of steaming arms may be difficult to effectively sanitise, as could worn, damaged plastic jugs or other equipment / utensils in poor condition

Hand Washing:

Wash hands thoroughly with soap and hot water, then dry with a clean paper towel. Hand sanitisers do not remove allergens.

Aprons and Cloths:

Ensure aprons and cloths are freshly laundered.

Storage and Preparation of Allergen-Free Foods

Handle and Manage Allergens

Food business operators must handle and manage food allergens effectively.

Stop and Concentrate

Staff should stop all other tasks and give full attention to the preparation of an allergen-free drink.

Storage:

Store ingredients and equipment for allergen-free meals/drinks in lidded, labelled containers. Consider colour coding these containers.
Allergen-free alternatives e.g. soya or almond milks should be stored separately from allergen-containing products within your fridge. Any drips or spills within your fridge must be cleaned and sanitised immediately.
Cups or mugs should be kept inverted and stored on a clean, sanitised surface and protected from any allergen contamination. Consider using a takeaway cup from new, unopened packaging.

Designated Area:

Use a designated area to prepare allergen-free drinks/foods with separate, designated equipment and utensils. Consider preparing the drink in a distinctive cup so that it is easily recognisable from other drinks.

Managing Food Safety and Keeping Records

Safer Food Better Business Pack:

Complete and review the new safe methods “Food Allergies – Food Hypersensitivity” and “Separating Foods” in the Cross Contamination section, and “Managing Food Allergen Information” in the Management section.

Alternative Systems:

If using an alternative documented food safety management system, ensure it covers food allergies, allergen information provision, and cross-contamination risks. Any ‘near misses’ should be recorded so that the reasons that led to potentially serving an incorrect drink or any mistakes can be reviewed to ensure that a similar incident does not recur.

Keep Original Packaging

To ensure the traceability of ingredients, it is recommended to avoid decanting them from their original packaging. This practice helps maintain the traceability of supplier and batch numbers, which is crucial for compliance with the General Food Regulations 2004. If decanting is necessary, it is essential to retain information on allergens and batch numbers. Proper traceability allows for the identification of any contamination sources and ensures that warnings about potential cross-contamination can be communicated to customers effectively

Warning

No Guarantee:

Remember, you do not have to guarantee that a meal/drink is free of a particular allergen. If you cannot guarantee this, you must explain it to the customer when discussing allergens. You must consider cross contamination risks and if the drink does contain that allergen, even in tiny amounts, you risk making a customer seriously ill and also commit criminal offences. People have also died after experiencing allergic reactions to food.

Training

Food businesses must make sure that staff receive training on allergens and are all aware of your internal policies and procedures for allergen management. Free staff training is available on the Food Standards Agency website Allergy training for food businesses | Food Standards Agency (opens in a new tab)
The Greater Gwent Food Group has produced allergen resources translated into various languages. These resources include videos featuring two real-life stories that provide insight into living with an allergy and highlight the tragic consequences that can occur if food businesses do not effectively manage allergens Trading Standards food allergen guidance (opens in a new tab)

Business Advice and Support